Corporate Service Providers Act 2024 compliance — Eligibility and requirements checklist

Corporate Service Providers Act 2024 compliance is the registration and anti-money-laundering regime that every firm providing corporate secretarial, registered-office or nominee-director services in Singapore must now meet. Passed by Parliament on 2 July 2024, the Act replaces the older registered filing agent framework and holds providers directly accountable to ACRA for the integrity of the company records they lodge.

Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.

What the Corporate Service Providers Act 2024 compliance regime covers

The Corporate Service Providers Act 2024 creates a single, dedicated licensing and conduct framework for corporate service providers (CSPs). Where the previous rules sat largely within the ACRA registered filing agent scheme, the new Act draws the obligations together and extends them to any person carrying on the business of providing a corporate service in or from Singapore, whether or not they lodge filings themselves.

Corporate services caught by the regime include acting as, or arranging for, a company secretary; providing a registered office address; forming companies for clients; and arranging for nominee directors or shareholders. If your business touches any of these activities for a fee, registration as a CSP is the starting point of compliance.

Who must register, and who is exempt

Any firm that provides corporate services by way of business must register with ACRA as a CSP before it can continue to operate. This captures professional corporate secretarial firms, accounting practices that offer company administration, and law practices to the extent they carry on corporate service work outside the scope of their legal practice. In-house company secretaries who serve only their own group are generally outside the business test, because they are not providing the service to third parties for a fee.

Corporate Service Providers Act 2024 compliance — Timeline and process sits alongside this guide and walks through the practical registration steps in more depth. For the corporate secretarial view of the same obligations, see Shareholding Structures for Foreign Founders in Singapore: Individual on the Singapore Secretary Services hub.

Eligibility and requirements checklist for CSP registration

To register and stay registered, a CSP is expected to demonstrate the following:

• A fit-and-proper assessment of the business and its officers, directors and registered qualified individuals.
• At least one registered qualified individual (RQI) who has passed the relevant competency requirements and oversees the firm’s filings.
• Documented anti-money-laundering and countering-the-financing-of-terrorism (AML/CFT) policies, including customer due diligence, screening and record-keeping.
• Ongoing monitoring of clients and the beneficial owners behind them.
• Proper controls over any nominee director arrangements, which are now tightly regulated.

Nominee directors and beneficial ownership

One of the sharpest changes is the treatment of nominee directors. A person may act as a nominee director by way of business only if they are arranged through a registered CSP, and the nominee relationship must be disclosed to ACRA and recorded in the company’s registers. The aim is to close the gap that allowed opaque control structures to hide behind local resident directors.

Beneficial ownership transparency runs through the whole Act. CSPs are expected to identify the natural persons who ultimately own or control each client entity, keep that information current, and make it available to ACRA on request. This mirrors the register of registrable controllers obligations that already apply to Singapore companies under the Companies Act 1967.

Cost, timeline and penalties

Budget realistically for the registration and its upkeep. Indicative figures practitioners should plan around:

• ACRA registration and annual renewal fees for a CSP, payable per firm.
• Professional competency examination costs of a few hundred Singapore dollars per registered qualified individual.
• Internal cost of building AML/CFT policies, screening tools and staff training, which for a small firm can run from S$3,000 to S$15,000 in the first year.

Enforcement teeth are significant. Financial penalties for breaches of the CSP framework and related AML failures were raised sharply, with fines that can reach up to S$100,000 per breach for the most serious conduct. Directors and officers who fail to discharge their duties can be personally liable. Section 157A(1) of the Companies Act 1967 provides that the business of a company is managed by, or under the direction of, its directors, and the CSP regime layers a gatekeeper duty on top of that management responsibility.

Common mistakes and gotchas

The errors we see most often are treating registration as a one-off box-tick, failing to refresh customer due diligence when a client changes ownership, and keeping nominee arrangements off the formal record. A second recurring gap is weak screening: running a name once at onboarding and never again. Ongoing monitoring is an express expectation, not a courtesy. Employers that also sponsor foreign staff should align their governance here with their immigration compliance, which we cover in EP renewal, salary uplift and dependency ratios — Eligibility and requ.

How the pieces fit together

Read the CSP Act 2024 alongside the Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024, which tightened related record-keeping and nominee disclosure rules. Because commencement of the various provisions has been staged, confirm the operative dates for the obligations that affect you before relying on any single deadline. ACRA remains the authoritative source; guidance from the regulator at sso.agc.gov.sg and the wider AML framework maintained by www.mas.gov.sg should be checked against your firm’s own facts.

FAQs

Does the Corporate Service Providers Act 2024 apply to a small one-person secretarial firm?
Yes. The test is whether corporate services are provided by way of business, not the size of the firm. A sole practitioner offering company secretarial or registered-office services for a fee must register as a CSP.

Can I still offer nominee director services?
Only through a registered CSP, with the arrangement disclosed to ACRA and recorded in the company registers. Undisclosed nominee arrangements are the specific practice the Act is designed to stop.

What are the penalties for non-compliance?
Financial penalties were raised substantially, reaching up to S$100,000 per breach for serious conduct, with possible personal liability for officers who fail in their duties.

How does this differ from the old registered filing agent rules?
The CSP Act consolidates and extends the older regime into a dedicated statute, adds explicit AML/CFT and beneficial-ownership duties, and regulates nominee directorships directly.

Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.